EBF response to ECB T2S

27 June 2007

The EBF responded to the ECB’s consultation on the user requirements for TARGET2-Securities noting that the proposals lacked clear definitions up front. Overall the EBF was in complete agreement with almost two third of the high level proposals. However, EBF could not come to a view based on the proposal No 18 on reference data on non-harmonised deadlines and schedules.

“Any CSD participating to T2S should no longer have any harmonised deadlines for settlement in central bank money, but should comply with T2S ones”, the EBF notes. “It is unclear why cross border settlement would take place outside T2S.”
The EBF stressed that based on principle 8, T2S should only settle in central bank money and there should be no commingling of central bank money and commercial bank money within T2S and at CSD level. It is also important to emphasise that in this context it is of the utmost importance to have Giovannini Barriers 4 and 7 eliminated.

For a complete understanding of the high level proposals the FBE calls for a clear definition of the terms “Participant”, “Investor”, End-investors”, and “System operator”.

Enclosed letter
Response template

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